United States
Environmental Protection
Agency
Air and Radiation
(6202J)
EPA430-R-99-007
January 1999
www.epa.gov/lmop
<&EPA Georgia State Primer
A Primer on
Developing Georgia's
Landfill Gas-to-Energy
Potential
LANDFILL METHANE
OUTREACH PROGRAM
The Georgia Environmental Facilities Authority
Printed on paper that contains at least
30 percent postconsumer fiber.
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Introduction j
1. About the Landfii! Methane Outreach Program i
2. Eiectricity Restructuring and LFGTE ill
3, The Goals of This Primer iv
4, Where to Go for More information v
1:
1. Overview of Federal Standards and Permits 1
1.1 Resource Conservation and Recovery Act Subtitle D 1
1,2 Clean Air Act (CAA) 2
NMOC Emissions: New Source Performance Standards (NSPS) 2
Air Emissions: New Source Review (NSR) Permitting Process 2
Title V Operating Permit 4
1,3 National Pollutant Discharge Elimination System (NPDES) Permit 5
1.4 Clean Water Act, Section 401 5
1.5 Other Federal Permit Programs 6
2. State Standards and Permits 7
3, Overview of Local Standards and Permits 20
Part 2: Incentiwe Programs
1. Overview of Federal Incentive Programs 23
1,1 Section 29 Tax Credit 23
1,2 Renewable Energy Production Incentive (REPI) 23
1,3 Qualifying Facilities Certification 24
2. Overview of State Funding Programs 25
2.1 Recycling and Solid Waste Facilities Loan Program 25
2.2 Recycling and Waste Reduction Grants 25
Tables
Table A Candidate Landfills for LFGTE Projects in Georgia ii
Table 2,1 Summary Table of State Standards/Permits 8
Table 2,2 Permit Approval Time Line 9
Table 2,3 Summary of Landfill Gas Systems Criteria 10
Table 2,4 Air Quality Construction and Operation Permits 12
Table 2.5 Title V (Part 70) Operating Permits 14
Table 2,6 Solid Waste Handling Permits 16
Table 2.7 Notification of Hazardous Waste Activity, Generators, Transporters and Facilities 17
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Introduction
Q About the Landfill Methane Outreach Program
The EPA Landfill Methane Outreach Program
The recovery of energy from landfill gas provides local and global environmenfal and energy benefits, as well as
economic benefits. The mefhane captured from landfills can be transformed into a cost-effective fuel source for
generating electricity and heat, firing boilers, or even powering vehicles.
To promote the use of landfill gas as an energy resource, the U.S. Environmental Protection Agency (EPA) has
established the Landfill Methane Outreach Program (LMOP). The goals of LMOP are to reduce methane emis-
sions from landfills by:
• Encouraging environmentally and economically beneficial LFGTE development
• Removing barriers to developing LFGTE projects
To achieve these goals, EPA establishes alliances with four key constituencies:
• State environmental and energy agencies
• Energy users/providers (including investor-owner, municipal and other public power utilities, cooperatives,
direct end users, and power marketers)
• Industry (including developers, engineers, and equipment vendors)
• Community partners (municipal and small private landfill owners and operators; cities, counties, and other
local governments; and community groups)
EPA establishes these alliances through a Memorandum of Understanding (MOU). By signing the MOU, each ally
acknowledges a shared commitment to promoting landfill gas energy recovery at solid waste landfills, recognizes
that the widespread use of landfill gas as an energy resource will reduce methane and other air emissions, and
commits to certain activities that enhance the development of this resource.
As of January 1999, over 240 landfill methane recovery projects were operating in the United States. EPA esti-
mates that up to 750 landfills could install economically viable landfill energy projects by the year 2000.
LFGTE Projects in Georgia
Georgia is a member of the LMOP State Ally Program, which encourages cooperation between EPA and state
energy and environmental agencies to promote the development of LFGTE resources. Georgia's Landfill Gas
Recovery Program focuses on developing consensus among landfill operators, utility companies, independent
power producers, project developers, utility regulators, and the state's regulators so they can work together to
promote new energy and environmental opportunities from which all Georgia residents will benefit.
Three LFGTE projects were operating in Georgia as of July 1998, and three were planned. According to EPA and
the state of Georgia, 16 landfills have the potential to support economically viable LFGTE projects. The following
table lists Georgia's 16 candidate landfills.
A Primer on Developing Georgia's Landfill Gas-to-Energy Potential
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Table A
Candidate Landfills for LFGTE Projects in Georgia
Landfill Name
Arnold Road LF
Atlanta-Gun Club Rd.
Atlanta-Key Rd.
Baker Place Rd.
BF1-Roberts Rd.
Columbus— Schatulga Rd.
Dean Bridge Rd.
Fleming/Gaissert Rd.
Forsyth, Old Brent Rd.
Seminole Rd.
Southern States— Bolton Rd.
Southern States-SR 90/SR 127
Speedway-SR 324
UWL Inc.-Richland Creek
WMI-Live Oak
WMI-Rolling Hills
County
Gwinnett
Fulton
Fulton
Columbia
Fayette
Muscogee
Richmond
Dougherty
Monroe
Dekalb
Fulton
Taylor
Barrow
Gwinnett
Dekalb
Clayton
Operational Status
Open
Open
Ceased receiving waste/In closure
Open
Closed
Open
Open
Open
Ceased receiving waste/In closure
Open
Closed
Open
Ceased receiving waste/In closure
Open
Open
Closed
Source: EPA's Opportunities for Landfill Gas Energy Recovery in Georgia: Draft Profiles of Candidate Landfills and Current Projects
and information provided by the state of Georgia.
Landfill Gas Projects in Georgia
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Electricity Restructuring and LFGTE
What Is Electricity Restructuring?
Electricity restructuring refers to the introduction of competition into both the wholesale and retail electricity mar-
kets. Until now, electric utilities operated under monopolies authorized by federal and state regulatory authorities
as the sole provider of electric service to consumers within a specific service territory. Under restructuring, utili-
ties will lose these monopolies, enabling other energy providers to compete for their customers. The result will
be more energy options for consumers, lower energy prices, and greater use of renewable energy sources.
Efforts to restructure the electric utility industry began in 1978 with passage of the Public Utilities Regulatory
Policies Act (PURPA), which required utilities to buy a portion of their power from unregulated power generators
in an effort to encourage the development of smaller generating facilities, new technologies, and renewable energy
sources. The National Energy Policy Act of 1992 (EPACT) expanded on PURPA, allowing more types of unregulated
companies to generate and sell electricity, effectively creating a competitive wholesale market for electric power.
Restructuring at the retail level has been a hot issue in many states since the passage of EPACT, which delegat-
ed to states the authority to introduce competition among electric utilities within their borders. As of January
1999, fourteen states have since enacted some form of restructuring legislation, while the remaining 36 are
considering such legislation.
How Do These Changes Affect Landfill Gas Recovery?
Many states are including renewable energy provisions in their restructuring legislation. Such provisions mandate
utilities to include a certain percentage of electricity generated from renewable, or "green energy," sources into
their energy mixes. LFGTE is one such green energy source.
In March 1998, the Clinton Administration unveiled its "Comprehensive Electricity Competition Plan" to restruc-
ture the electricity industry nationwide. Contained in this proposal is a Renewable Portfolio Standard (RPS) that
would guarantee that a minimum percentage of the nation's electricity be powered by green energy. Energy ser-
vice providers would be required to cover a percentage of their electricity sales with generation from non-hydro-
electric renewable sources such as wind, solar, geothermal, and biomass (which includes LFGTE).
Marketing Landfill Gas Recovery as Green Power
One of the emerging areas and most promising mechanisms to encourage utilities and other energy marketers
to participate in LFGTE projects is the development of green marketing programs. Green marketing programs
are designed to enable energy marketers to position renewable energy products (including LFGTE) as premium
products, and therefore, collect a premium price from their customers. In addition, green marketing allows energy
marketers in competitive marketplaces to differentiate their energy product, and allows utilities in non-restruc-
tured marketplaces to gain critical product marketing experience in preparation for competition. However, the
general public is less familiar with LFGTE than other sources of renewable energy; support from the LMOP is
often critical to ensure the success of early LFGTE green marketing efforts.
Get the Latest Information on Electricity Restructuring in Your State
For up-to-date information on electricity restructuring in Georgia and elsewhere, visit the National Conference
of State Legislatures Web site at: http://www.ncsl.org/programs/esnr/restru.htm. This site contains a glossary
of terms related to restructuring, as well as links to the full text of restructuring legislation passed by states.
A Primer on Developing Georgia's Landfill Gas-to-Energy Potential \ \ \
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The Goals of This Primer
Permits, incentive programs, and policies for LFGTE project development vary greatly from state to state. To guide
LFGTE project developers through the state permitting process and to help them to take advantage of state incen-
tive programs, the LMOP has worked with state agencies to develop individual primers for states participating in
the State Ally Program. By presenting the latest information on federal and state regulations and incentives affect-
ing LFGTE projects in this primer, the LMOP and Georgia state officials hope to facilitate development of many of
the landfills listed in Table A.
To develop this primer, the state of Georgia identified all the permits and funding programs that could apply
to LFGTE projects developed in Georgia. It should be noted, however, that the regulations, agencies, and policies
described are subject to change. Changes are likely to occur whenever a state legislature meets, or when the feder-
al government imposes new directions on state and local governments. LFGTE project developers should verify and
monitor the status of laws and rules that might affect their plans or the operations of their projects.
Who Should Read This Primer?
Throughout the country, the number of landfill gas-to-energy (LFGTE) projects is growing. Recovering methane
gas at solid waste landfills provides significant environmental and economic benefits by eliminating methane
emissions while capturing the emissions' energy value.
This primer is designed to help realize the potential of landfill gas recovery in the state of Georgia. It provides infor-
mation for developers of LFGTE projects, as well as all other participants in such projects: landfill operators, utility
companies, independent power producers, utility regulators, state regulators, engineers, and equipment vendors.
What Information Does This Primer Contain?
If you are interested in taking advantage of the economic and environmental opportunities in LFGTE recovery in
Georgia, you will need to know the regulatory requirements that apply. You will also need to know what economic
incentives are available to help make these projects more economically viable.
To address these needs, this primer covers the following topics:
• Federal Standards and Permits. This section provides information on federal regulations that may pertain to
LFGTE projects, including solid waste, air quality, and water quality regulations.
• State Standards and Permits. This section provides information on state permits that apply to landfill gas
recovery projects in the state of Georgia.
• Local Standards and Permits. Local permit approval will often be needed for LFGTE projects. This section
offers a step-by-step process you can follow to secure this approval.
• Federal Incentive Programs. This section presents information on federal incentives that may apply to
LFGTE projects.
• State Funding Programs. This section presents information on the environmental infrastructure financing
opportunities that are available in the state of Georgia.
iv Landfill Gas Projects in Georgia
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Where Can I Go for More Information?
James L Thompson
(Georgia Landfill Methane Outreach Program State Ally Contact)
Georgia Environmental Facilities Authority
100 Peachtree Street, 20th Floor
Atlanta, Georgia 30303
(404) 656-0938
U.S. Environmental Protection Agency
Landfill Methane Outreach Program
U.S. EPA, 6202J
401 M Street, SW
Washington, DC 20460
Phone: (888) 782-7937
Fax: (202) 565-2077
A Primer on Developing Georgia's Landfill Gas-to-Energy Potential
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Part 1: Standards and Permits
IT
Overview of Federal Standards and Permits
The following section discusses federal regulations that may pertain to LFGTE projects. The LFGTE
projects can be subject to solid waste, air quality, and water quality regulations. The federal regulations
are presented in general terms, because individual state/local governments generally develop their own
regulations for carrying out federal mandates. Specific requirements may therefore differ among states.
Project developers will have to contact relevant federal agencies and, in some cases, state agencies for
more detailed information and applications. The discussion of each key federal standard/permit contains
three components:
• Importance of the standard/permit to LFGTE project developers
• Applicability to LFGTE projects
• Description of each standard/permit
1.1 Resource Conservation and Recovery Act Subtitle D
Importance Before a LFGTE project can be developed, all Resource Conservation and Recovery
Act (RCRA) Subtitle D requirements (i.e., requirements for non-hazardous waste
management) must be satisfied.
Applicability Methane is explosive in certain concentrations and poses a hazard if it migrates
beyond the landfill facility boundary. Landfill gas collection systems must meet
RCRA Subtitle D standards for gas control.
Description Since October 1979, federal regulations promulgated under Subtitle D of RCRA
required controls on migration of landfill gas. In 1991, EPA updated landfill design
and performance standards. The newer standards apply to municipal solid waste
landfills that were active on or after October 9, 1993. Specifically, the standards
require monitoring of landfill gas and establishing performance standards for com-
bustible gas migration control. Monitoring requirements must be met at landfills
not only during their operation, but also for a period of 30 years after closure.
Landfills affected by RCRA Subtitle D are required to control gas by establishing a program to periodically
check for methane emissions and prevent offsite migration. Landfill owners and operators must ensure
that the concentration of methane gas does not exceed:
• 25 percent of the lower explosive limit for methane in facilities' structures
• The lower explosive limit for methane at the facility boundary
Permitted limits on methane levels reflect the fact that methane is explosive within the range of 5 to 15
percent concentration in air. If methane emissions exceed permitted limits, corrective action (i.e., installa-
tion of a landfill gas collection system) must be taken. Subtitle D may provide an impetus for some land-
fills to install energy recovery projects in cases where a gas collection system is required for compliance
(see 40 CFR Part 258 for more information).
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1.2 Clean Air Act (CAA)
The CAA regulates emissions of pollutants to ensure that air quality meets specified health and welfare
standards. The CAA contains two provisions that may affect LFGTE projects: New Source Performance
Standards (NSPS) and New Source Review (NSR). Facilities that are planning to construct a new LFGTE
system or that plan to modify a landfill operation to incorporate a LFGTE system must obtain a Permit to
Construct and Operate from the responsible air regulatory agency if emissions from the project are expect-
ed to exceed the major facility emission thresholds. The Permit to Construct and Operate specifies the
NSPS and NSR requirements that the project must meet. Once construction is complete, the facility must
obtain an operating permit that meets the requirements defined in Title V of the 1990 CAA Amendments.
The general requirements of NSPS, NSR, and Title Vfor LFGTE projects are discussed below.
Non-Methane Organic Compounds Emissions (NMOCs): New Source
Performance Standards (NSPS)
Importance LFGTE projects can be part of a compliance strategy to meet EPA's new emissions
standards for landfill gas.
Applicability Landfills meeting certain design capacity, age, and emissions criteria are required to
collect landfill gas and either flare it or use it for energy.
Description EPA final regulations under Title I of the CAA Amendments require affected landfills to
collect and control landfill gas. Specifically, the CAA targets reductions in the emis-
sions of NMOCs found in landfill gas because they contribute to local smog formation.
For landfills last modified on or before May 30, 1991, and that received waste after
November 8, 1987 ("existing landfills"), the standards are "Emissions Guidelines" (EG),
which has been incorporated as Georgia Rule (ggg)—"Municipal Solid Waste Landfills."
For landfills that began construction or accepted waste for the first time on or
after May 30, 1991 ("new landfills"), the standards are "New Source Performance
Standards" (NSPS). The final regulations can be found in the Federal Register, March
12, 1996, Vol. 61, No. 49, pgs. 9907-9944, or can be obtained from the National
Technical Information Service (NTIS) at (703) 487-4650. Ask for PB96-153465.
The basic requirements to determine if controls for landfill gas are necessary are the same for both
existing and new landfills. Landfills that exceed both of the following criteria must comply with collection
system requirements.
• Capacity—Maximum design capacity greater than or equal to 2.5 million Mg1 (or 2.75 million tons)
or 3.27 million yd3
• Emissions—Annual NMOC emission rate is greater than 50 metric tons.
Air Emissions: New Source Review (NSR) Permitting Process
Importance New LFGTE projects may be required to obtain p re-const ruction permits under New
Source Review (NSR). Depending on the area in which the project is located, obtain-
ing these permits may be the most critical aspect of project approval.
Applicability The combustion of landfill gas results in emissions of carbon monoxide and oxides
of nitrogen. Requirements vary for control of these emissions depending on local air
quality. The relevant standards for a particular area will be discussed in Section 2,
"'landfills with less than 2.5 million Mg are required to file a design capacity report.
2 Landfill Gas Projects in Georgia
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State Standards and Permits. Applicability of these standards to LFGTE projects will
depend on the level of emissions resulting from the technology used in the project
and the project's location (i.e., attainment or non-attainment area).
Description CAA regulations require new stationary sources and modifications to existing
sources of certain air emissions to undergo NSR before they can operate. The pur-
pose of these regulations is to ensure that sources meet the applicable air quality
standards for the area in which they are located. Because these regulations are com-
plex, a landfill owner or operator may want to consult an attorney or expert familiar
with NSR for more information about permit requirements in a particular area. Air
permitting requirements should also be discussed with the Air Protection Branch of
Georgia's Environmental Protection Division.
The existing CAA regulations for attainment and maintenance of ambient air quality standards regulate
six criteria pollutants—ozone, nitrogen dioxide (NC^), carbon monoxide (CO), particulate matter (PM-2.5 and
PM-10), sulfur dioxide (802), and lead. The CAA authorizes the EPA to set both health- and public welfare-
based national ambient air quality standards (NAAQS) for each criteria pollutant. Areas that meet the
NAAQS for a particular air pollutant are classified as being in "attainment" for that pollutant and those that
do not are in "non-attainment." Because each state is required to develop an air quality implementation plan
(called a State Implementation Plan or SIP) to attain and maintain compliance with the NAAQS in each Air
Quality Control Region within the state, specific permit requirements will vary by state. Currently, Atlanta is
the only "non-attainment" area in Georgia for ozone. (See 40 CFR 51.160-51.166 for more information.)
The location of the LFGTE project will dictate which kinds of construction and operating permits are
required. If the landfill is located in an area that is in attainment for a particular pollutant, the LFGTE
project must undergo Prevention of Significant Deterioration permitting if emission levels exceed major
source thresholds. Nonattainment area permitting is required for those landfills that are located in areas
that do not meet the NAAQS for a particular air pollutant. Furthermore, the level of emissions from the
project determines whether the project must undergo major NSR or minor NSR. The requirements of
major NSR permitting are greater than those for minor NSR. The following section provides more detail
on new source permits.
Prevention of Significant Deterioration Permitting
Prevention of Significant Deterioration (PSD) review is used in attainment areas to determine whether a
new or modified emissions source will cause significant deterioration of local air quality. Georgia's Air
Protection Branch can assist landfill gas project developers in determining whether a proposed LFGTE
project requires PSD approval.
All areas are governed to some extent by PSD regulations because no location is in attainment for all
criteria pollutants. Applicants must determine PSD applicability for each individual pollutant. For gas-fired
sources, PSD major NSR is required if the new source will emit or has the potential to emit any criteria
pollutant at a level greater than 250 tons per year.
For each pollutant for which the source is considered major, the PSD major NSR permitting process
requires that the applicants determine the maximum degree of reduction achievable through the applica-
tion of available control technologies. Specifically, major sources may have to undergo any or all of the
following four PSD steps:
• Best Available Control Technology (BACT) analysis
• Monitoring of local air quality
A Primer on Developing Georgia's Landfill Gas-to-Energy Potential
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• Source impact analysis/modeling
• Additional impact analysis/modeling (i.e., impact on vegetation, visibility, and Class I areas)2
Minor sources and minor modifications (i.e., below 250 tons per year) are exempt from this process, but
these sources may still be required to obtain construction and operating air permits (see CFR. 40 CFR
52.21 for more information on PSD).
Nonattainment Air Permitting
An area that does not meet the NAAQS for one or more of the six criteria pollutants is classified as being
in "nonattainment" for that pollutant. Ozone is the most pervasive nonattainment pollutant, and the one
most likely to affect LFGTE projects. (The Atlanta metro-area is a nonattainment area for ozone.) A pro-
posed new emissions source or modification of an existing source located in a nonattainment area must
undergo nonattainment major NSR if the new source or the modification is classified as major (i.e., if the
new or modified source exceeds specified emissions thresholds). To obtain a nonattainment NSR permit
for criteria pollutants, the project:
• Must use technology that achieves the Lowest Achievable Emissions Rate (LAER) for the
nonattainment pollutant
• Must arrange for an emissions reduction at an existing source that offsets the emissions from
the new project at specific ratios
Potential Exemptions
EPA recently furnished a guidance document to state and regional permitting authorities that provides an
exemption from major NSR permitting requirements for landfill projects that qualify as "pollution control
projects." An existing landfill that plans to install a LFGTE recovery project may qualify as a pollution
control project as long as it reduces non-methane organic compounds (NMOC) at the site. Under the
guidance, the permitting authority may exempt the project from major NSR, provided it meets all other
requirements under the CAA and the state, including minor source requirements. In nonattainment areas,
offsets will still be required, but need not exceed a 1:1 ratio. States have discretion to exercise the
increased flexibility allowed by the guidance on a case-by-case basis.
Title V Operating Permit
Importance Many LFGTE projects must obtain operating permits that satisfy Title V of the 1990
CAA Amendments.
Applicability Any LFGTE plant that is a major source, as defined by the Title V regulation (40 CFR
Part 70), must obtain an operating permit.
Description Title V of the CAA requires that all major sources obtain new federally enforceable
operating permits. Title V is modeled after a similar program established under the
National Pollution Discharge Elimination System (NPDES). The purpose of Title V is
to clarify, in a single document, all the air requirements applicable to a facility. Each
major source subject to Title V must submit an application for an operating permit to
Georgia's Air Protection Branch describing and quantifying all air pollution sources.
The operating permit describes the emission limits and operating conditions that a
facility must satisfy, and specifies the reporting requirements that a facility must meet
to show compliance with the air pollution regulations. A Title V operating permit
must be renewed every 5 years.
2Class I areas are specified under the Clean Air Act and include national parks. Projects situated within a certain
distance from Class I areas are subject to more stringent criteria for emissions levels.
Landfill Gas Projects in Georgia
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1.3 National Pollutant Discharge Elimination System (NPDES) Permit
Importance LFGTE projects may need to obtain National Pollutant Discharge Elimination System
(NPDES) permits for discharging wastewater that is generated during the energy
recovery process.
Applicability Landfill gas condensate forms when water and other vapors condense out of the gas
stream due to temperature and pressure changes within the collection system. This
wastewater must be removed from the collection system. In addition, LFGTE projects
may generate wastewater from system maintenance and cooling tower blowdown.
Description NPDES permits regulate discharges of pollutants to surface waters. The authority to
issue these permits is delegated to state governments by EPA. The permits, which
typically last 5 years, limit the quantity and concentration of pollutants that may be
discharged. To ensure compliance with the limits, permits require wastewater treat-
ment or impose other operation conditions. The state water offices or EPA regional
office can provide further information on these permits.
The permits are required for three categories of sources and can be issued as individual or general
permits. A LFGTE project would be included in the "wastewater discharges to surface water from
industrial facilities" category and would require an individual permit. An individual permit application
for wastewater discharges typically requires information on water supply volumes; water utilization;
wastewater flow; characteristics and disposal methods; planned improvements; storm water treatment;
plant operation; materials and chemicals used; production; and other relevant information.
1.4 Clean Water Act, Section 401
Importance LFGTE projects may need Clean Water Act (CWA) Section 401 certification for
constructing pipelines that cross streams or wetlands.
Applicability Landfill gas recovery collection pipes or distribution pipes from the landfill to a near-
by gas user may cross streams or wetlands. When construction or operation of such
pipes causes any discharge of dredge into streams or wetlands, the project may
require Section 401 certification.
Description If the construction or operation of facilities results in any discharge into streams or
wetlands, such construction is regulated under Section 401. This requirement may
affect the construction of LFGTE project facilities or pipelines to transport landfill gas.
The applicant must obtain a water quality certification from the State in which the discharge will
originate. The certification should then be sent to the U.S. Army Corps of Engineers. The certification
indicates that such discharge will comply with the applicable provisions of Sections 301, 302, 303, 306,
and 307 of the CWA.
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1.5 Other Federal Permit Programs
The following are brief descriptions of how ofher federal permifs could apply fo LFGTE project developmenf:
• RCRA Subfifle C could apply fo a landfill gas project if it produces hazardous waste. While some
landfill gas projects can return condensate to the landfill, many dispose of it through the public
sewage system after some form of on-site treatment. In some cases, the condensate may contain
high enough concentrations of heavy metals and organic chemicals for it to be classified as a haz-
ardous waste, thus triggering federal regulation.
• The Historic Preservation Act of 1966 or the Endangered Species Act could apply if power lines or
gas pipelines associated with a project infringe upon an historic site or an area that provides habi-
tat for endangered species.
Landfill Gas Projects in Georgia
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B s*a*e Standards and Permits
This section provides summarized information on permits required by the state of Georgia for the devel-
opment of a LFGTE project.3 Information provided on each permit includes: how the permit is applicable
to LFGTE projects; the appropriate agency contact; a description of the permit; the statute/regulation;
information required and suggestions for a successful application; the application and review process;
the review/approval period; and any fees required. For an overview of required permits, contact informa-
tion, and length of the review period, see Tables 2.1 and 2.2.
Air-Related Issues: For Title V purposes, landfills that are contiguous or adjacent can be considered
one site. Or, a landfill that is owned and operated by one party, while the control system is owned or
operated by a second party, can be considered under common control and one site. Although these
facilities are considered one site for purposes of Title V permitting, the state of Georgia allows for
separate Title V applications from each facility. If you believe that your facility and a neighboring facility
can be considered one site, please contact the Air Protection Branch for a Site Determination. The
Title V and SIP Construction/Operation applications are available from the Air Protection Branch by
calling (404) 363-7000.
The Air Protection Branch does not charge a processing fee for any of the required applications.
However, the Air Protection Branch does have an emission-based fee program. This Air Permit Fee
Program meets the requirements of 40 CFR Part 70. Actual fees are based on emissions, and fees are
currently charged at $25 per ton of emission. For more information on this program, please acquire
Georgia's document "Procedures for Calculating Air Permit Fees." This document can be obtained by
calling (404) 363-7000.
3The permits contained in this handbook were suggested by state permitting agencies.
A Primer on Developing Georgia's Landfill Gas-to-Energy Potential
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Table 2.1
Summary Table of State Standards/Permits
Standard
Air
Permit
Permit to Construct/
Operate Title V
(Part 70)
Agency/Contact
Environmental Protection Division (EPD)
Georgia Air Protection Branch
Stationary Source Permitting Program
Jim Burt
Atlanta Tradeport, Suite 120
4244 International Parkway
Atlanta, Georgia 30354
(404) 363-7000
Review Period
90+ days for a
minor source
180+ days for a
major source or
major modification
Waste
(Hazardous/Solid)
Solid Waste Handling
Permit
EPD
Land Protection Branch
Solid Waste Management Program
Barbara Howard, P.E.
Atlanta Tradeport, Suite 104
4244 International Parkway
Atlanta, Georgia 30354
(404) 362-2572
90 days
Notification of
Hazardous Waste
Activity, Generators,
Transporters, and
Facilities
EPD
Hazardous Waste Mgmt. Branch
Corrective Action Program
Shelly Stroud
205 Butler Street, S.E.
Suite 1154
Atlanta, Georgia 30334
(404) 656-7802
4 to 6 weeks
Water
Groundwater
Discharge Permit
Not permitted in the state of Georgia
Not applicable
Surface Water
Discharge Permit
EPD
Water Protection Branch
Permitting, Compliance and
Enforcement Program
Mike Creason
Atlanta Tradeport, Suite 110
4244 International Parkway
Atlanta, Georgia 30354
(404) 362-2680
3 to 6 months
Pretreatment
Discharge Permit
Local municipality
Depends on the per-
mitting municipality
Landfill Gas Projects in Georgia
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Table 2.2
Permit Approval Time-line
Air
Construction/Operation
* Title V
Waste
Solid Waste
** Hazardous
Water
Surface
***Pretreatment
024
Months
8 10 12 14
Notes
Solid black line denotes the minimum review/approval
period (where applicable); gray line denotes the maximum.
* There is not a standard review time for this permit.
* * Review time for hazardous waste is 4-6 weeks.
' * * Depends on the permitting municipality.
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Table 2.3
Summary of Landfill Gas Systems Criteria
Type of Project
Specific Criteria
Landfill Gas
Collection System
Introduction
Extraction and control systems for landfill gas can be categorized according to:
• Function (active, passive, or structure protection)
• Location (perimeter or interior)
• Technique used (air injection, barrier trench, vacuum assisted, etc.)
Applications used in LFGTE projects emphasize the use of active extraction systems
applied to interior systems with the use of vacuum to actively extract landfill gas.
In general, this choice of application grants an effective operation of the landfill gas
extraction system that can minimize or eliminate problems such as gas migration
and subsurface fires.
General Guidelines
LFGTE will be reviewed on a case-by-case basis by the state's Solid Waste Management
Program. However, some general guidance documents regarding the design will be
provided. Unless otherwise approved by the Solid Waste Management Program all gas
recovery systems must at least include the following design features:
1. At a minimum, the collection system is to include:
A. Gas extraction devices or wellheads and each should have a sampling
port with temperature, gauge pressure, and nitrogen or oxygen concen-
tration measuring capabilities and/or devices.
B. Leachate and Condensate Management with:
1. Accessibility
2. Air Intrusion Control
3. Corrosion Resistance
4. Resistance to waste heat of decomposition
C. Extraction devices cannot be located in asbestos and other non-
degradable material.
D. Collection System Materials of Construction
1. PVC
2. HOPE
3. Fiberglass
4. Stainless Steel and other nonporous corrosion resistant materials that
meet required engineering design criteria.
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Type of Project
Specific Criteria
Landfill Gas
Collection System,
continued
E. Connector assembly for header pipes and system components is to
include:
1. Positive closing throttle valve
2. Necessary seals and couplings
3. Access couplings
2. Maintenance of the collection system is to include monitoring of the following
landfill gas parameters:
1. Gauge pressure at header pipes
2. Nitrogen or oxygen concentration
3. Temperature
3. A surface emissions monitoring plan of both the active and closed waste lifts
and side slopes.
A site design and operational plan minor modification for the collection system
design and construction is to be submitted to the Solid Waste Management Program
for review and approval. Along with the gas collection plan modification, applicable
modifications to landfill design, operation and closure/post closure care plans should
be submitted to the Solid Waste Management Program for review and approval.
Modifications are required to address site plan revisions due to the addition of the
collection and flare or combustion unit, specifically:
1. Location of the flare and/or combustion unit(s).
2. Settlement due to the addition of the methane collection and (if applicable)
combustion system.
3. Records of maintenance and monitoring of the landfill as prescribed by the
NSPS regulations and the Solid Waste Management Rules for a minimum of
five years.
The remainder of Section 2 contains information about each of the permits required by Georgia for project
development. The information is organized in tables and each table contains the following information about
the subject permit:
Applicability to Landfill Gas Projects
Agency Contact
Description
Statute/Regulation
Information Required/Suggestions
Application Process
Review Process
Review/Approval Period
Fee
A Primer on Developing Georgia's Landfill Gas-to-Energy Potential
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Table 2.4
Air Quality Construction and Operation Permits
Applicability to
Landfill Gas Projects
All equipment collecting and treating landfill gas, (which typically includes open and
enclosed flares, internal combustion engines, boilers and fuel storage tanks) are
subject to state air regulations.
Agency Contact
Environmental Protection Division (EPD)
Air Protection Branch
Stationary Source Permitting Program
Jim Burt
Atlanta Tradeport, Suite 120
4244 International Parkway
Atlanta, Georgia 30354
(404) 363-7000
Description
Construction and Operation Permits may be required for landfill gas collection and
treatment projects. Pre-Approval: Before an air pollution source is constructed or
modified, a permit must be obtained from the Air Protection Branch. Post-Approval:
Periodic emissions tests and/or reports may be required for some sources, depend-
ing on the nature of the operation and its emissions. The EPD will issue a state per-
mit to operate when satisfied that the company operations will comply with all
applicable air quality requirements.
Statute/Regulation
Federal
State
The Clean Air Act, Section 110 and Title V, 42 U.S.C. 7401 et seq.
Part I of Chapter 9 of Title 12 of the O.C.G.A. Section 12-9-1, et seq.
Information
Required/Suggestions
A description of the landfill gas collection system, expected landfill gas production
rates and estimated pollution emissions over the life of the project, and air pollution
control equipment.
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Application Process The air pollution emission rates showing compliance with the applicable regulation
are to be submitted on state air permit application forms along with the associated
drawings and descriptions.
Review Process The EPD will perform a technical review of the application and determine if the
project will be in compliance with all applicable regulations. The EPD will notify the
applicant of any deficiencies. The EPD will prepare tentative determinations and
make the draft permit available for review. A notice will be prepared for publication
in the local newspaper.
Review/Approval 90+ days. Time may vary depending on complexity and completeness of the permit
Period application. The range reflects the completeness of the initial application, the com-
plexity of the installation and the need for information, etc.
Fees No standard application fee. Consult Georgia "Procedures for Calculating Air Permit
Fees" for emission-related fees.
A Primer on Developing Georgia's Landfill Gas-to-Energy Potential 13
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Table 2.5
Title V (Part 70) Operating Permits
Applicability to
Landfill Gas Projects
Companies subject to Title V include the following:
A. Facilities subject to acid rain requirements under Title IV of the Clean Air Act
B. Facilities (major sources) with a potential to emit:
• 100 tons per year or more of any regulated pollutant
• 50 tons per year of VOC or NOx in the Non-Attainment Area
• 10 tons per year or more of a single hazardous air pollutant (HAP)
• 25 tons per year of any combination of HAPs
C. Facilities subject to CAA § 111 (New Source Performance Standards) or § 112
(HAPs). At this time, facilities that do not fall under the major source definition
listed above under these categories are deferred from Part 70 requirements.
Agency Contact
EPD
Air Protection Branch
Stationary Source Permitting and Compliance Programs
Jim Burt and James Eason
Atlanta Tradeport, Suite 120
4244 International Parkway
Atlanta, Georgia 30354
(404) 363-7000
Description
Title V of the Clean Air Act of 1990 (CAA) introduced an operating permit program,
the purpose of which is to clarify, in a single document, all the air requirements
applicable to a company. As specified before, companies subject to Title V must sub-
mit a complete application for a federally-enforceable operating permit to the state
according to a schedule specified by the EPD.
Statute/Regulation
Federal
State
The Clean Air Act, Title V (42 USC §§ 7401 et seq.): 40 CFR Part 70
Part of Chapter 9 of Title 12 of the O.C.G.A. Section 12-9-1, et seq.
Information
Required/Suggestions
Facilities subject to Part 70 requirements must describe and quantify pollution
sources and identify all federally-enforceable requirements. A Part 70 permit must be
renewed every 5 years.
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Application Process The facility submits an application to the EPD that describes and quantifies pollution
sources and identifies federally enforceable requirements.
Review Process Within 60 days of receipt of an application, the EPD makes a completeness determi-
nation. Once a facility's application is deemed administratively complete, the EPD per-
forms a technical review and issues a draft permit. EPA and neighboring states will
have the opportunity to review draft permits. EPA also has the authority to object to a
Title V permit. In addition, a citizen may also petition EPA to make an objection.
Review/Approval There is no data on permit processing times because Part 70 is a new program.
Period
Fees No standard application fee. Consult Georgia "Procedures for Calculating Air Permit
Fees" for emission-related fees.
A Primer on Developing Georgia's Landfill Gas-to-Energy Potential 15
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Table 2.6
Solid Waste Handling Permits
Applicability to
Landfill Gas Projects
LFGTE projects are considered a minor modification to the solid waste disposal per-
mit for landfills.
Agency Contact
EPD
Land Protection Branch
Solid Waste Management Program
Barbara Howard, P.E.
Atlanta Tradeport, Suite 104
4244 International Parkway
Atlanta, Georgia 30354
(404) 362-2572
Description
State solid waste rules are implemented by the Solid Waste Management Program of
EPD. In order to add or change the landfill gas systems at an existing landfill, owners
or operators are required to obtain state approval of a minor modification to the exist-
ing landfill solid waste handling permit.
Statute/Regulation
Federal
State
Resource Conservation and Recovery Act (RCRA) Subtitle D and 40 CFR Parts 257
and 258.
Rules of Georgia, Department of Natural Resources, EPD, Chapter 391-3-4, Solid
Waste Management.
Information
Required/Suggestions
A description and justification of design and operational plans, drawings showing
systems and components, construction quality assurance programs, and verification
of compliance with other regulatory entities.
Application Process
The appropriate state application forms for a minor modification are to be submitted
along with the appropriate design and operational plans showing the modifications.
Review Process
The EPD conducts technical reviews. The applicant is notified of any deficiencies.
Approval is issued after deficiencies have been addressed.
Review/Approval
Period
Up to 90 days
Fees
None
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Table 2.7
Notification of Hazardous Waste Activity, Generators, Transporters
and Facilities
Applicability to The development of an landfill gas project may result in the generation, treatment,
Landfill Gas Projects storage, and transport of a hazardous waste.
Agency Contact EPD
Hazardous Waste Management Branch
Corrective Action Program
Shelly Stroud
205 Butler Street. S.E.
Suite 1154
Atlanta, Georgia 30334
(404) 656-7802
Description
Generators, transporters, and facilities that treat, store, and dispose of hazardous
waste must notify the Georgia EPD/Hazardous Waste Management Branch by sub-
mitting EPA Form 8700-12 (Notification of Regulated Waste Activity). This form pro-
vides information to EPD as to the hazardous waste activities to be conducted at the
facility. A facility that indicates that it intends to treat, store, or dispose of a hazardous
waste will be required to submit a permit application. The regulatory requirements for
the permit application process are found in 40 CFR Part 270.10 or Chapter 391-3-11-
.11 of the Georgia Rules for the Management of Hazardous Waste.
Statute/Regulation
Federal
State
Resource Conservation and Recovery Act (RCRA) Subtitle C and 40 CFR
Parts 262.12, 263.11 and 264.11
Georgia Rules for the Management of Hazardous Waste, Chapter 391-3-11-.04
Application Process
The appropriate 8700-12 forms are submitted to the EPD.
Review Process
The Notification of Regulated Hazardous Waste Activity form is reviewed, processed
and a permanent EPA Identification Number is assigned to the facility. The informa-
tion from the form is recorded in the Resource Conservation and Recovery
Information System.
Review/Approval
Period
4-6 weeks
Fees
None
A Primer on Developing Georgia's Landfill Gas-to-Energy Potential 17
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Table 2.8
Surface Water Discharge Permit
Applicability to
Landfill Gas Projects
Landfill gas projects may need to comply with this requirement if they discharge
wastewater to the surface waters of the state.
Agency Contact
EPD
Water Protection Branch
Permitting, Compliance and Enforcement Program
Mike Creason
Atlanta Tradeport, Suite 110
4244 International Parkway
Atlanta, Georgia 30354
(404) 362-2680
Description
The surface water discharge permit combines the requirements of the state dis-
charge permit program and the National Pollutant Discharge Elimination System
(NPDES) into one permit for industrial facilities that discharge to state surface waters.
The permit is designed to meet federal effluent guidelines when applicable and also
ensure the discharge satisfies state water quality standards. All facilities that dis-
charge wastewater directly to surface waters need this permit.
Statute/Regulation
Federal
Federal Clean Water Act
State
Georgia Water Quality Control Act
Information
Required/Suggestions
NPDES application forms 1 and 2 C
Application Process
The permit application forms must be completed in full prior to submittal to the EPD.
Review Process
The EPD will review the application, develop permit limits, and provide an opportunity
for public participation by publishing notice of the application. The EPD develops per-
mit limits and publishes a notice of tentative determination and conducts a public
hearing if requested. The EPD issues the permit if the final determination is not con-
tested. If contested, administrative procedures for the appeal process are followed.
Review/Approval
Period
3 to 6 months
Fees
None
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Table 2.9
Pretreatment Discharge Permit
Applicability to
Landfill Gas Projects
Landfill gas projects may need to comply with this requirement if they discharge
wastewater to a sanitary sewer.
Agency Contact
Local municipality
Description
A locally issued pretreatment permit is usually required for those facilities that seek to
discharge to municipal wastewater treatment systems. For some of the smaller munic-
ipal systems, the pretreatment permits are issued by the EPD.
Statute/Regulation
Federal
State
Local
40 CFR 403 (for significant industrial users)
Georgia Water Quality Control Act
Local ordinance is applicable to all users.
Application Process
Pretreatment permits are usually issued by local municipalities. The state and federal
requirements become applicable only when a facility is defined as a significant indus-
trial user by 40 CFR 403.
Review Process
The review is usually performed at the local level.
Review/Approval
Period
Depends on the permitting municipality.
Fees
Depends on the permitting municipality.
A Primer on Developing Georgia's Landfill Gas-to-Energy Potential 19
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Overview of Local Standards and Permits
Within the framework of federal and state regulation, local governments will have some jurisdiction over
LFGTE development in nearly all cases. Typically, local permits address issues that affect the surrounding
community. These permits generally fall under the categories of construction, environment and health,
land use, and water quality/use. Local governments are also responsible for administering some permits
for federal and state regulations in addition to their own. For example, many local governments are
responsible for ensuring compliance with federal air quality regulations. It should be noted, however, that
some local standards and regulations are more strict than state or federal regulations.
Steps to Successful Local Permit Approval:
The following six steps will assist LFGTE project developers to achieve successful local permit approval:
Step 1 Determine which local authorities have jurisdiction over the project site.
Step 2 Contact local, city, and/or county planning and public works departments to obtain infor-
mation about applicable permits and to discuss your plans. Meeting with agency staff to
discuss the landfill gas project and required permits often helps expedite the permitting
process.
Step 3 Obtain essential information regarding each permit, including:
• what information is required
• the permitting process that should be followed
• time frames (including submittal, hearing, and decision dates)
Step 4 Obtain copies of the regulations to compare and verify what is required in the permit
applications. If they differ, contact the appropriate permitting agency.
Step 5 Submit a complete application. Incomplete applications typically result in processing
delays.
Step 6 Attend meetings or hearings where the application will be discussed to respond to any
questions that are raised. Failure to do so could result in delays.
Typical Local Permits
The table on the following page provides typical local permits and approvals required for LFGTE projects.
20 Landfill Gas Projects in Georgia
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Table 3.1
Local Permits and Standards
Permit
Description
Building Permit
Most county/local governments require building permits for construction, which entail
compliance with several types of building codes, such as plumbing and electrical. A
typical building permit application may require detailed final plans for structures,
including electrical and plumbing plans, floor layout, sewage facilities, a storm water
drainage plan, size and shape of lot and buildings, setback of buildings from proper-
ty lines and drain field, access, size and shape of foundation walls, air vents, window
access, and heating or cooling plants (if included in the design).
Zoning/Land Use
Most communities have a zoning and land use plan that identifies where different
types of development are allowed (i.e., residential, commercial, and industrial). The
local zoning board determines whether a particular project meets local land use
criteria and can grant variances if conditions warrant. A landfill gas project may
require an industrial zoning classification.
Storm Water
Management
Some local public works departments require a permit for discharges during con-
struction and operation of a LFGTE project. Good facility design that maintains the
pre-development runoff characteristics of the site will typically enable the project to
meet permitting requirements easily.
Solid Waste Disposal
A LFGTE project may generate solid wastes, such as packaging material, cleaning
solvents, and equipment fluids. If the landfill is closed, disposal of these solid wastes
may be subject to review by a local authority.
Wastewater
The primary types of wastewater likely to be generated by a LFGTE project include
maintenance wastewater and cooling tower blowdown. The city engineer's office
should be contacted to provide information about available wastewater handling
capacity and any unique condensate treatment requirements or permits for landfills.
Fire Hazards
and Precautions
The mix of gases in landfill gas has a moderate to high explosion potential; methane is
explosive in concentrations of 5 to 15 percent in air. Because methane has the poten-
tial to migrate from the landfill to on-site or off-site structures, it poses a significant pub-
lic safety hazard. EPA requires that methane concentrations be less than 5 percent at
a landfill property line, and less than 1.5 percent in a facility's structures. County regu-
lations may call for even stricter standards to be observed at the landfill.
Noise
Most local zoning ordinances stipulate the maximum allowable decibel levels from
noise sources. These levels vary depending on the location of the site. For example,
LFGTE projects located near residential areas will likely have to comply with stricter
noise level standards than projects located in non-populated areas.
A Primer on Developing Georgia's Landfill Gas-to-Energy Potential
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Part 2: Incentive Programs
Q Overview of Federal Incentive Programs
There are three federal incentive programs that may apply to LFGTE projects: the Section 29 Tax Credit,
the Renewable Energy Production Incentive (REPI), and the Qualifying Facilities (QF) Certification. Each
program is described below.
1.1 Section 29 Tax Credit
Developers of LFGTE projects who sell landfill gas to an unrelated third party may qualify for a tax credit
under Section 29 of the Internal Revenue Service (IRS) tax code. As a result of this stipulation, project
developers may bring in an outside party when developing power projects in order to take advantage of
the credits. Section 29 Tax Credit was established in 1979 to encourage development of unconventional
gas resources, such as landfill gas. Section 29 tax credits are available through 2007 to landfill gas
projects that have a gas sales agreement in place by December 31, 1996 and are placed in service by
June 30, 1998. The credit has been extended several times by the U.S. Congress, but there is no guaran-
tee that these extensions will continue. The credit is worth $3.00 per barrel of oil-equivalent (on a MMBtu
basis) and is adjusted annually for inflation.
1.2 Renewable Energy Production Incentive (REPI)
The Renewable Energy Production Incentive (REPI), mandated under the Energy Policy Act of 1992, may
provide a cash subsidy of up to $0.15 per kWh to publicly owned qualified renewable energy sources,
such as landfills, for the period October 1993 through September 2003.4 The Department of Energy
(DOE) will make incentive payments for 10 fiscal years, beginning with the fiscal year in which application
for payment for electricity generated by the facility is first made and the facility is determined by DOE to
be eligible for receipt of an incentive payment. The period for payment under this program ends in fiscal
year 2013.
For further information, contact:
U.S. Department of Energy
National Renewable Energy Laboratory
Golden Field Office
Golden, Colorado 80403
Phone: (303) 275-4706
U.S. Department of Energy
Efficiency and Renewable Energy
Forrestal Building, Mail Station EE-10
1000 Independence Avel, S.W.
Washington, DC 20585
Phone: (202) 586-4564
4Final Rule Making, 10 Federal Register Part 451, July 19, 1995, Vol. 60, No. 138.
A Primer on Developing Georgia's Landfill Gas-to-Energy Potential
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1.3 Qualifying Facilities Certification
LFGTE projects that generate electricity will benefit from Qualifying Facilities (QF) certification, which
is granted through the Federal Energy Regulatory Commission (FERC). The following describes the
benefits of QF status and the steps for applying for such status.
The Public Utility Regulatory Policies Act (PURPA)—one of five parts of the National Energy Act of 1978—
was designed to promote conservation of energy and energy security by removing barriers to the devel-
opment of cogeneration facilities and facilities that employ waste or renewable fuels. Such facilities are
called Qualifying Facilities, or QFs. Under PURPA, utilities are required to purchase electricity from QFs
at each utility's avoided cost of generating power. PURPA provides that a small power production facility,
such as a LFGTE project that meets its standards, can become a QF.
In order to apply for QF status, applicants must prepare either (1) a Notice of Self-Certification, which
asserts compliance with the Commissions' technical and ownership criteria, or (2) an Application for
Commission Certification of Qualifying Status, which requires a draft Federal Register notice and which
provides actual Commission approval of QF status. In either case, the applicant must also file Form 565,
which is a list of questions about the project, and must pay any filing fees associated with certifications,
exemptions, and other activities. FERC will provide the QF "Info Packet" that describes the necessary
steps, requirements, and background information. After submittal of the initial application, further justifi-
cations and submittal of information may be required.
For the QF Info Packet and applications, contact:
Federal Energy Regulatory Commission
Qualifying Facilities Division
825 North Capital Street, N.E.
Washington, DC 20426
Phone: (202) 208-0571
24 Landfill Gas Projects in Georgia
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JIJ Overview of State Funding Programs
This section provides information regarding the environmental infrastructure financing opportunities avail-
able through the Georgia Environmental Facilities Authority (GEFA). GEFA is a state agency that, among
other responsibilities, makes state-backed low interest loans to cities, counties, and solid waste manage-
ment authorities for water, sewer and solid waste projects. The following summarizes GEFA's loan and
grant programs for solid waste management infrastructure improvement projects, which could include
landfill gas projects.
2.1 Recycling and Solid Waste Facilities Loan Program
GEFA's municipal solid waste loan program finances solid waste management solutions, particularly facili-
ties that help to minimize the waste stream or to mitigate environmental hazards. The maximum loan
amount is up to $2 million; the maximum term is up to 20 years. The current interest rate is 4.76%.
Applications are accepted at anytime. Landfill gas projects can be financed under this program. The
Solid Waste Facilities Loan Program is limited to Georgia cities, counties and solid waste management
authorities only. GEFA is not empowered under Georgia law to make loans or grants to private or non-
profit organizations. Partnerships with private sector developers and/or project operators may be permis-
sible depending on specific project arrangements. GEFA is pleased to discuss specific project financing
possibilities at anytime. There are no application fees or closing costs associated with the loan program.
Please contact GEFA at (404) 656-0938 for more information.
2.2 Recycling and Waste Reduction Grants
Grants are available to help local governments build facilities and purchase equipment for recycling or
waste reduction programs. The maximum grant amounts are: $10,000 per single jurisdiction, $25,000
per multi-jurisdictional application. These grants are available until funds are exhausted. Funding cycles
usually occur once per calendar year. Contact GEFA for the latest information on this program. Potential
funding for landfill gas projects may be discussed with the program manager.
A Primer on Developing Georgia's Landfill Gas-to-Energy Potential 25
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